RACE TO THE TOP

States Implementing 

Teacher and Principal 

Evaluation Systems 

despite Challenges

Report to the Chairman, Committee 

on Education and the Workforce, 

House of Representatives

September 2013

GAO-13-777

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-777, a report to the 

Chairman, Committee on Education and the 

Workforce, House of Representatives 

September 2013

RACE TO THE TOP

States Implementing Teacher and Principal 

Evaluation Systems despite Challenges

Why GAO Did This Study

Education created RTT under the 

American Recovery and Reinvestment 

Act of 2009 to provide incentives for 

states to reform K-12 education in 

areas such as improving the lowest 

performing schools and developing 

effective teachers and leaders. In 

2010, Education awarded 12 states 

nearly $4 billion in RTT grant funds to 

spend over 4 years. A state’s RTT 

application and scope of work included

the state’s plans for development and 

implementation of teacher and 

principal evaluation systems by 

participating school districts. These 

systems assess teacher and principal 

effectiveness based on student 

academic growth and other measures, 

such as observation of professional 

practice. Currently, additional states 

are designing and implementing similar 

evaluation systems.

GAO was asked to review RTT teacher 

and principal evaluation systems. This 

report examines (1) the extent to which 

the 2010 grantee states have 

implemented their teacher and 

principal evaluation systems, (2) the 

challenges the grantee states have 

faced in designing and implementing 

these systems, and (3) how Education 

has helped grantee states meet their 

RTT objectives for teacher and 

principal evaluation systems.

GAO reviewed relevant federal laws, 

regulations, and guidance; analyzed 

RTT applications and documentation 

on each state’s guidelines for their 

evaluation systems; and interviewed 

officials from all 12 states, selected 

districts, and Education.

What GAO Recommends

GAO is not making recommendations 

in this report. 

What GAO Found

By school year 2012-13, 6 of 12 Race to The Top (RTT) states fully implemented 

their evaluation systems (i.e., for all teachers and principals in all RTT districts). 

However, their success in fully implementing by the date targeted in their RTT 

applications varied. Three of these states met their target date while three did not 

for various reasons, such as needing more time to develop student academic 

growth measures. The six states that did not fully implement either piloted or 

partially implemented. The scope of pilots varied. One state piloted to about 14 

percent of teachers and principals while another piloted to about 30 percent of 

teachers. State or district officials in four of the six states expressed some 

concerns about their readiness for full implementation. 

Officials in most RTT states cited challenges related to developing and using 

evaluation measures, addressing teacher concerns, and building capacity and 

sustainability. State officials said it was difficult to design and implement rigorous 

student learning objectives—an alternate measure of student academic growth. 

In 6 states, officials said they had difficulty ensuring that principals conducted 

evaluations consistently. Officials in 11 states said teacher concerns about the 

scale of change, such as the use of student academic growth data and 

consequences attached to evaluations, challenged state efforts. State and district 

officials also discussed capacity challenges, such as too few staff or limited staff 

expertise and prioritizing evaluation reform amid multiple educational initiatives. 

Officials in 10 states had concerns about sustaining their evaluation systems.

Education helps RTT states meet their goals for teacher and principal evaluation

systems through a new monitoring process and through technical assistance. 

Education officials said the RTT monitoring process differs from other monitoring 

efforts in the frequency of contact with the states and the emphasis on 

continuous improvement and quality of RTT reforms. Officials from 8 of the 12

RTT states expressed generally positive views about Education’s monitoring. 

When states have not demonstrated adequate progress, Education has taken 

corrective action. For example, Education designated two states as high-risk, 

which resulted in additional monitoring. Education provides technical assistance 

through a contractor; officials from 10 RTT states told us assistance related to

evaluation systems was generally helpful. Education officials said they plan to 

provide RTT and nongrantee states with more information to support their efforts. 

View GAO-13-777. For more information, 

contact George Scott at (202) 512-7215 or 

scottg@gao.gov.
Page i GAO-13-777 Race to the Top Evaluation Systems

Letter 1

Background 4

Six of 12 RTT States Fully Implemented Their Evaluation Systems 

by the 2012-13 School Year 12

Most RTT States Cited Challenges with Developing and Using 

Certain Evaluation Measures, Addressing Teacher Concerns, and 

Building Capacity and Sustainability 16

Education Supports RTT State Implementation Efforts through 

Monitoring and Technical Assistance 25

Concluding Observations 33

Agency Comments and Our Evaluation 33

Appendix I Comments from the U.S. Department of Education 35

Appendix II GAO Contact and Staff Acknowledgments 36

Related GAO Products 37

Department of Education 37

Recovery Act 38

Tables

Table 1: Race to the Top Grant Awards, by Phase and Amount 

Awarded 5

Table 2: Race to the Top State Selection Criteria 6

Figures

Figure 1: Example Components of Race to the Top States’ 

Evaluation Systems 11

Figure 2: Implementation Status for Race to the Top States’ 

Evaluation Systems, School Year 2012-13 13

Figure 3: Capacity Challenges Faced by Race to the Top States 21

Figure 4: Examples of Race to the Top State and Selected District 

Efforts to Address Capacity Challenges 23

Contents
Page ii GAO-13-777 Race to the Top Evaluation Systems

Figure 5: Cases of Technical Assistance Provided by the Reform 

Support Network to Race to the Top States on Teacher 

and Leader Effectiveness, Calendar Years 2010-2013 29

Abbreviations

Education U.S. Department of Education

ESEA Elementary and Secondary Education Act of 1965

Recovery Act American Recovery and Reinvestment Act of 2009

RSN Reform Support Network

RTT Race to the Top

SLOs student learning objectives

SY school year

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-13-777 Race to the Top Evaluation Systems

441 G St. N.W.

Washington, DC 20548

September 18, 2013

The Honorable John P. Kline

Chairman

Committee on Education and the Workforce

House of Representatives

Dear Chairman Kline:

The U.S. Department of Education (Education) created Race to the Top 

(RTT) to provide incentives for states to implement large-scale, farreaching reforms to improve student achievement, close achievement 

gaps, and increase graduation and college enrollment rates.1 This 

program is part of the current administration’s larger effort to ensure that 

students are college and career ready. RTT is the largest competitive 

grant fund ever administered by Education, and in 2010, Education 

awarded nearly $4 billion in grant funds to 12 states. To be competitive 

for RTT grants, states had to demonstrate a commitment to reforming K12 education across four interconnected areas: adopting standards and 

assessments, building data systems, supporting teachers and principals, 

and improving the lowest-achieving schools. Among the reforms related 

to teachers and principals, Education called for states and their 

participating school districts to improve teacher and principal 

effectiveness by developing evaluation systems that, in part, take into 

account data on student academic growth and inform personnel 

decisions, such as compensation, promotion, and retention.2

 1 The American Recovery and Reinvestment Act of 2009 (Recovery Act) established the 

State Fiscal Stabilization Fund and required Education to use it for, among other 

purposes, “State Incentive Grants” to states that make significant progress in meeting 

specified education-related objectives. Pub. L. No. 111-5, §14006, 123 Stat. 115, 283. 

Education subsequently established the Race to the Top grant fund to implement this 

provision.

Education is 

also using other means to encourage reforms of teacher and principal 

evaluation systems. Currently, many non-RTT states and districts are 

designing and implementing evaluation systems to receive waivers from 

certain requirements of the Elementary and Secondary Education Act 

2 Throughout this report, we use the term student academic growth to mean student 

growth, as defined by Education for the purposes of RTT. In addition, we use the term 

school districts or districts to refer to local educational agencies.
Page 2 GAO-13-777 Race to the Top Evaluation Systems

(ESEA) of 1965, as amended.3

In 2011, we found that some states faced challenges implementing their 

RTT initiatives.

In addition, Education has prioritized 

evaluation system reform by setting a goal in its strategic plan to increase 

the number of states and districts that have comprehensive teacher and 

principal evaluation systems. More broadly, the current administration has 

included evaluation systems as an area of reform in its blueprint for 

revising ESEA. 

4 We also found that states had made amendments to their 

RTT plans—including their evaluation systems—such as changes to 

costs and timelines.5

In conducting this work, we focused on the 12 states that received RTT 

grant funds in 2010.

You asked us to provide information about RTT 

grantees’ progress toward implementing their teacher and principal 

evaluation systems. In this report, we examined (1) the extent to which 

the 2010 grantee states have implemented their teacher and principal 

evaluation systems; (2) the challenges the grantee states have faced in 

designing and implementing these systems; and (3) how Education has 

helped grantee states meet their RTT objectives for teacher and principal 

evaluation systems.

6

 3 Under the ESEA, as amended, states and school districts may request a waiver of 

certain ESEA requirements from the Secretary of Education. 20 U.S.C. § 7861. To receive 

the waivers, Education requires states and districts to implement certain programs and 

policies, including the development and implementation of teacher and principal 

evaluation and support systems that meet criteria similar to those used for RTT. As of 

August 5, 2013, in addition to the 12 RTT states in our review, 28 states were approved 

for ESEA waivers, and requests from 8 additional states (including Puerto Rico and the 

Bureau of Indian Education) were under review, according to information on the 

Department of Education’s website, 

We interviewed state officials from all 12 grantee

states as well as school district officials in Maryland, New York, and North 

Carolina, either in person or by phone. We chose states that differed in 

terms of the flexibility they provided to districts to design their teacher and 

principal evaluation systems (Maryland and New York offer districts more 

flexibility, whereas North Carolina has a statewide evaluation system and 

http://www.ed.gov/esea/flexibility.

4 GAO, Race to the Top: Reform Efforts are Under Way and Information Sharing Could Be 

Improved, GAO-11-658 (Washington, D.C.: June 30, 2011).

5 GAO, Race to the Top: Characteristics of Grantees’ Amended Programs and Education’s 

Review Process, GAO-12-228R (Washington, D.C.: Dec. 8, 2011). 

6 Throughout this report, we refer to the District of Columbia as a state.
Page 3 GAO-13-777 Race to the Top Evaluation Systems

offers districts less flexibility). In selecting these states, we also 

considered the RTT award amount and the percentage of students 

served by school districts participating in RTT. We interviewed a total of 

12 school districts in these three states. We asked state officials to 

identify districts that varied in terms of the design of their evaluation 

systems (if applicable) and the range of challenges they faced. Other 

criteria included whether a district was urban, suburban, or rural and the 

percentage of high-poverty or high-minority schools in the district.7

In addition, we reviewed documents to obtain information on states’

guidelines for the evaluation systems used by their districts, including 

each state’s RTT application, teacher and principal evaluation system 

manuals, and progress reports developed by the states and Education. 

We also reviewed relevant federal laws, regulations, and guidance and 

interviewed Education officials from the Implementation and Support Unit, 

as well as officials from the contractor Education hired to provide 

technical assistance. We obtained data from the contractor on the 

number and types of technical assistance activities provided to RTT 

states. We assessed the reliability of data by interviewing agency officials 

knowledgeable about the data and determined that the data were 

sufficiently reliable for the purposes of this report. The American 

Recovery and Reinvestment Act of 2009 (Recovery Act) requires that we 

conduct bimonthly reviews of how the act’s funds are used by selected 

states and localities.

The 

views of these 12 districts cannot be generalized to all districts that 

participated in RTT, but they do provide important insights into some 

districts’ experiences with RTT implementation. The state and district 

officials we interviewed provided information on the key components of 

their evaluation systems, the implementation status of these systems, 

what they considered to be their design and implementation challenges, 

and Education’s monitoring activities and technical assistance. We also 

interviewed officials from unions or organizations representing teachers or 

principals in Maryland, New York, and North Carolina to obtain their 

perspectives on design and implementation challenges.

8

 7 We used the National Center for Education Statistics’ Common Core of Data to examine 

these different characteristics. We assessed relevant documentation to determine that 

these data were sufficiently reliable for our purposes. 

This report fulfills this requirement in that we 

8 Pub. L. No. 111-5, § 901, 123 Stat. 115, 191.
Page 4 GAO-13-777 Race to the Top Evaluation Systems

examined the use of Recovery Act funds by the 12 states that were 

awarded RTT grants in 2010.

We conducted this performance audit from August 2012 through

September 2013 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.

In accordance with Recovery Act requirements, Education established the 

RTT grant fund to encourage states to reform their K-12 education 

systems and to reward states for improving student outcomes, such as 

making substantial gains in student achievement and improving high 

school graduation rates. States competed for RTT grant funds based on 

reforms across four areas:

• adopting standards and assessments that prepare students to 

succeed in college and the workplace and to compete in the global 

market;

• building data systems that measure student academic growth and 

success and inform teachers and principals about how they can 

improve instruction;

• recruiting, developing, rewarding, and retaining effective teachers and 

principals, especially where they are needed most; and

• turning around the lowest-achieving schools.

Education awarded RTT grants in three phases. Twelve states received 

grants in 2010 in Phases 1 and 2 to support the design and 

implementation of their teacher and principal evaluation systems and 

Background

RTT Overview
Page 5 GAO-13-777 Race to the Top Evaluation Systems

other RTT reforms.9 Award amounts ranged from $75 million to $700 

million (see table 1). States were required to subgrant at least 50 percent 

of their total grant award to districts that chose to participate in RTT. The 

4-year grant period began on the date funds were awarded to the state. 

States must obligate all funds within that period, and they have 90 days 

following the end of their grant period to liquidate all obligated funds

unless they receive a no-cost extension. Education may grant extensions 

for states beyond the 90 days on a case-by-case basis.10

Table 1: Race to the Top Grant Awards, by Phase and Amount Awarded 

Any Phase 1 

and Phase 2 funds not obligated and liquidated by September 30, 2015, 

will revert to the U.S. Treasury.

State 

Total amount 

awarded

(Dollars in millions)

Date grant 

awarded

Expected 

end date

Phase 1

Tennessee 501 7/26/2010 7/25/2014

Delaware 119 6/11/2010 6/10/2014

Phase 2

Florida 700 9/24/2010 9/23/2014

New York 697 9/24/2010 9/23/2014

Georgia 400 9/24/2010 9/23/2014

Ohio 400 9/24/2010 9/23/2014

North Carolina 399 9/24/2010 9/23/2014

Maryland 250 9/24/2010 9/23/2014

Massachusetts 250 9/24/2010 9/23/2014

District of Columbia 75 9/24/2010 9/23/2014

 9 In 2011, Education granted funds to seven additional states in Phase 3 of RTT. Phase 3 

grantees were chosen from those that applied for but did not receive funds in Phase 2. 

Education has also awarded other RTT grants since the inception of RTT, including those 

under the Assessment, Early Learning Challenge, and District programs. Subsequent 

appropriations provided funding for some of these additional RTT grants. See, for 

example, Department of Education Appropriations Act, 2012, Pub. L. No. 112-74, div. F, 

tit. III, 125 Stat. 786, 1093 (2011) and Department of Defense and Full-Year Continuing 

Appropriations Act, 2011, Pub. L. No. 112-10, § 1832(a)(2), 125 Stat. 38, 163. This study 

only includes states funded through Phases 1 and 2 because these states have had more 

time to design and implement their evaluation systems.

10 34 C.F.R. § 80.23.
Page 6 GAO-13-777 Race to the Top Evaluation Systems

State 

Total amount 

awarded

(Dollars in millions)

Date grant 

awarded

Expected 

end date

Hawaii 75 9/24/2010 9/23/2014

Rhode Island 75 9/24/2010 9/23/2014

Total 3,941

Source: Department of Education grant award notification letters.

Education identified 19 primary criteria to guide peer reviewers in the 

selection of states for RTT grants (see table 2).11

Table 2: Race to the Top State Selection Criteria

Category Criteria

A. State Success Factors (A)(1) Articulating state’s education reform agenda and local educational agencies’

participation in it

(A)(2) Building strong statewide capacity to implement, scale up, and sustain 

proposed plans

(A)(3) Demonstrating significant progress in raising achievement and closing gaps

B. Standards and Assessments (B)(1) Developing and adopting common standards

(B)(2) Developing and implementing common, high-quality assessments

(B)(3) Supporting the transition to enhanced standards and high-quality 

assessments

C. Data Systems to Support Instruction (C)(1) Fully implementing a statewide longitudinal data system

(C)(2) Accessing and using state data 

(C)(3) Using data to improve instruction 

D. Great Teachers and Leaders (D)(1) Providing high-quality pathways for aspiring teachers and principals

(D)(2) Improving teacher and principal effectiveness based on performance

(D)(3) Ensuring equitable distribution of effective teachers and principals 

(D)(4) Improving the effectiveness of teacher and principal preparation programs

(D)(5) Providing effective support to teachers and principals

E. Turning Around the Lowest-Achieving Schools (E)(1) Intervening in the lowest-achieving schools and local educational agencies 

(E)(2) Turning around the lowest-achieving schools

 11 Race to the Top Fund, 74 Fed. Reg. 59,688 (Nov. 18, 2009). In awarding the RTT 

grants, Education used a peer review process to evaluate applications. At Education’s 

invitation, over 1,500 prospective reviewers applied or were nominated to review Phase 1 

RTT applications. Education ultimately selected 58 reviewers. 

Criteria for Awarding 

RTT Grants
Page 7 GAO-13-777 Race to the Top Evaluation Systems

Category Criteria

F. General Criteria (F)(1) Making education funding a priority

(F)(2) Ensuring successful conditions for high-performing charter schools and other 

innovative schools

(F)(3) Demonstrating other significant reform conditions

Source: 74 Fed. Reg. 59,688, 59,801-59,804 (Nov. 18, 2009).

Note: In addition to these criteria, Education gave states the option to include other proposals in their 

plans, such as proposals to prepare more students for advanced study and careers in science, 

technology, engineering, and mathematics fields and proposals for states to work together to develop 

joint longitudinal data systems.

The criterion—improving teacher and principal effectiveness based on 

performance— established the RTT guidelines for teacher and principal 

evaluation systems. Reviewers evaluated the state’s plan to ensure its 

participating RTT districts (1) measure student growth for each individual 

student; (2) design and implement evaluation systems, developed with 

teacher and principal involvement, that include multiple rating categories 

that take into account data on student growth as a significant factor; (3) 

evaluate teachers and principals annually and provide feedback, including 

student growth data; and (4) use these evaluations to inform decisions 

regarding professional development, compensation, promotion, retention, 

tenure, and certification.12

Education defines student growth as the change in student achievement 

for an individual student between two or more points in time. For students 

in grades and subjects that are tested by state standardized tests, 

Education defines student achievement as the score received on the 

state’s assessments required under the ESEA. For students in grades 

and subjects that are not tested by state standardized tests, Education 

defines student achievement based on alternative measures of student 

learning and performance. These measures include student scores on 

pre-tests and end-of-course tests, student performance on English 

language proficiency assessments, and other measures of student 

achievement that are rigorous and comparable across classrooms. 

Student achievement for students in tested grades and subjects can also 

 12 In their RTT applications, states provided a narrative response and other supporting 

information, such as a budget and implementation timelines. See 74 Fed. Reg. 59,688, 

59,803 (Nov. 18, 2009), criterion (D)(2) for Education’s complete criteria related to teacher 

and principal evaluation.
Page 8 GAO-13-777 Race to the Top Evaluation Systems

be assessed using other measures as appropriate, including the same 

measures as students in nontested grades and subjects.

Education provided background information in its notice of proposed 

priorities, requirements, definitions, and selection criteria for RTT on why 

it included student growth as a factor in its criteria for teacher and 

principal evaluation.13 Education noted the difficulty in predicting teacher 

quality based solely on the qualifications that teachers bring to the job. 

The department cited research on the limited predictive power of 

measures such as certification, education, and years of experience, and 

research on the value of measuring student growth to assess teacher 

quality.14 In response to public comments that expressed concern about 

the use of student growth data as the sole means to evaluate teachers 

and principals, Education revised its definitions of an effective teacher 

and effective principal to require that multiple measures be used to 

assess effectiveness, with student growth as a significant factor.15

Education also established criteria for peer reviewers to consider a state’s 

capacity to sustain its reforms. The criterion—building strong statewide 

capacity to implement, scale up, and sustain proposed plans—required 

reviewers to assess the extent to which the state had a plan to ensure 

sufficient capacity and use stakeholder support to implement its plans. 

States were evaluated on, among other things, the extent to which they 

demonstrated that they would provide strong leadership and dedicated 

teams to implement the reforms and use their fiscal, political, and human 

capital resources to continue successful grant-funded reforms after RTT 

funds are no longer available.

Education also provided examples of these supplemental measures, such 

as multiple observation-based assessments of teacher performance and 

high school graduation rates as a measure for evaluating principals.

16

 13 Race to the Top Fund, 74 Fed. Reg. 37,804 (July 29, 2009).

14 See 74 Fed. Reg. 37,804, 37,806 (July 29, 2009) for the specific studies Education 

cited. We did not assess the validity of these studies.

15 74 Fed. Reg. 59,688, 59,750-51 (Nov. 18, 2009).

16 See 74 Fed. Reg. 59,688, 59,801 (Nov. 18, 2009), criterion (A)(2) for Education’s 

complete criteria related to state capacity.
Page 9 GAO-13-777 Race to the Top Evaluation Systems

Education is responsible for fiscal and programmatic oversight of all 

aspects of RTT, reviewing and responding to states’ requests to amend 

their RTT applications, and providing technical assistance. To monitor 

states’ progress, Education established a program review process that 

includes ongoing conversations with grantees, on-site program reviews, 

grantee self-evaluations, and meetings with Education officials. As we 

reported previously, Education uses a common set of questions to 

oversee state progress and to address specific needs and challenges of 

each grantee.17 Education also publishes annual reports to the public 

summarizing the progress of each state. To provide technical assistance, 

Education established the Reform Support Network (RSN), a 4-year, $43 

million technical assistance contract with ICF International, which works 

with Education to support RTT states.18

Education’s process for reviewing and approving changes to a state’s 

RTT plans includes reviewing the state’s approved application, budget, 

and scope of work.19 According to Education’s guidance, an RTT grantee 

must submit an amendment request for (1) a proposed revision that 

constitutes a change in activities from the approved grant project, 

regardless of budgetary impact; (2) budgetary changes, including 

transfers among categories or programs, that exceed $500,000 of the 

current approved budget; or (3) changes to the list of districts participating 

with the grantee’s RTT plan. Education will not approve amendment

requests that would change the overall scope and objectives of the 

approved proposal, fail to comply with the terms of the award or the 

statutory and regulatory provisions of the program, or violate the general 

principles of the program.20

Education’s Institute of Education Sciences’ National Center for 

Education Evaluation and Regional Assistance is conducting two studies 

that relate to RTT teacher and principal evaluation systems. One study 

 17 GAO-11-658.

18 ICF International is a consulting firm that provides professional services and technology 

solutions to government and commercial clients.

19 Education’s regulations require grantees to obtain prior written approval from the 

department for certain changes. 34 C.F.R. § 80.30. In addition, Education provided 

specific guidance to RTT grantees on the circumstances for and types of allowable 

amendment requests for the program.

20 For more information on Education’s RTT amendment process, see GAO-12-228R. 

Role of the Department 

of Education
Page 10 GAO-13-777 Race to the Top Evaluation Systems

will assess the RTT and School Improvement Grant programs and 

whether these programs are related to improvement in student outcomes. 

The results of this study, which will not specifically assess the impact of 

teacher and principal evaluations on student outcomes, are expected in 

2014. In the second study, experimental teacher and principal evaluation 

systems will be implemented in schools in eight districts in order to study 

their effects on factors such as student achievement and teacher and 

principal mobility.21 A report on this study is expected in 2015.

The RTT states provide districts with varying amounts of flexibility to 

develop their evaluation systems. For example, some RTT states 

developed evaluation systems for use by all districts, unless a district 

develops an alternate evaluation system that meets state requirements. 

In other states, districts can develop their own evaluation systems within 

guidelines provided by the state, and the state must approve each 

district’s system.22

 21 Officials from the Institute of Education Sciences said they chose districts that did not 

have in place or did not plan to implement evaluation systems similar to the experimental 

evaluation systems.

Whether the evaluation system is developed by the 

state or the district, districts evaluate teachers and principals using 

multiple measures that assess professional practice and student 

academic growth (see fig.1).

22 In this report, when we discuss a state’s evaluation systems, we are referring to the 

evaluation systems implemented by RTT districts in that state. 

Teacher and Principal 

Evaluation Systems in 

the RTT States
Page 11 GAO-13-777 Race to the Top Evaluation Systems

Figure 1: Example Components of Race to the Top States’ Evaluation Systems

Note: This figure is intended to provide examples of the components used in RTT states’ evaluation 

systems; some states may not use the components described, and some states may use other 

measures beyond those included.
Page 12 GAO-13-777 Race to the Top Evaluation Systems

According to state officials, 6 of the 12 RTT states fully implemented both 

their teacher and principal evaluation systems by school year (SY) 2012-

13 (see fig. 2), though their success in meeting their original target date 

for implementation varied. The states that fully implemented their systems 

evaluated all teachers and principals in RTT districts, according to state 

officials.23 The six states that fully implemented both teacher and principal 

evaluation systems targeted SY 2011-12 for full implementation in their 

RTT applications. Three of the six states met that target and SY 2012-13 

was their second school year of full implementation. The other three

states did not meet the targets set in their applications, but did fully 

implement their systems in SY 2012-13.24

 23 We considered a state’s evaluation systems to be fully implemented if, according to 

state officials, all districts participating in RTT evaluated all of their teachers or principals 

using the major components of their new evaluation systems, even if not all assessment 

measures within the major components were used for every teacher or principal. We also 

considered evaluation systems to be fully implemented even if they were not used to 

inform personnel decisions or if some nonacademic staff, such as music teachers or 

district administrators, were evaluated differently while the state determined how to assess 

student academic growth for them.

According to Education’s 

amendment approval letters, states shifted implementation time frames, 

in part, because they needed additional time to develop student academic 

growth measures. For example, Delaware required an additional year to 

develop measures for its student academic growth component, which 

state officials said resulted in a better evaluation system.

24 All three of these states—Delaware, North Carolina, and Rhode Island—submitted 

amendment requests to Education regarding timeline shifts, and Education approved 

these changes.

Six of 12 

RTT States Fully 

Implemented Their 

Evaluation Systems 

by the 2012-13 

School Year
Page 13 GAO-13-777 Race to the Top Evaluation Systems

Figure 2: Implementation Status for Race to the Top States’ Evaluation Systems, 

School Year 2012-13

Note: We categorized New York as partially implemented because the New York City Department of 

Education did not implement a state-approved evaluation system in SY 2012-13. According to state 

officials, the district accounts for approximately 34 percent of teachers and principals statewide. 

Officials from the New York City Department of Education stated they plan to implement their new 

evaluation system for the first time in SY 2013-14.

The six states that did not fully implement both their teacher and principal 

evaluation systems in SY 2012-13 either piloted or partially implemented 

evaluation systems,25 according to state officials (see fig. 2). Based on 

the targets set in their RTT applications, four of the six states originally 

planned to fully implement by SY 2012-13 but are instead piloting or 

partially implementing their systems.26

 25 We considered an evaluation system to be piloted if, according to state officials, a state 

was field-testing part or all of its evaluation system. We considered a state evaluation 

system to be partially implemented if a state implemented all major components of the 

new evaluation system for some, but not all, teachers or principals in RTT districts.

The proportion of teachers and 

26 Georgia received Education’s approval to shift implementation time frames due, in part, 

to changes in state leadership. Maryland received Education’s approval to pilot district 

evaluation systems in SY 2012-13—rather than fully implementing them—in part so that 

districts would have more time to improve their systems before using them for personnel 

decisions and to provide additional training on the systems. New York and Massachusetts 

did not submit amendment requests for their timeline shifts. As noted previously, we 

categorized New York as partially implemented because the New York City Department of 

Education did not have a state-approved evaluation system in SY 2012-13. According to 

Education officials, they are working with Massachusetts to clarify the state’s plan for 

moving forward with full implementation and expect the state to submit a related 

amendment request.
Page 14 GAO-13-777 Race to the Top Evaluation Systems

principals participating in pilots varied. According to state officials, 

Hawaii’s teacher evaluation pilot covered about 30 percent of its teachers, 

and Maryland’s evaluation systems pilot covered about 14 percent of its 

teachers and principals in RTT districts. Among the four districts we 

visited in Maryland, district officials said the percentage of teachers who 

participated in the districts’ pilots ranged from about 4 percent to 100 

percent.27

According to RTT state officials, states are using or plan to use the results 

of their new teacher and principal evaluations to inform decisions 

regarding, among other things, professional development, compensation, 

and retention, in accordance with RTT.

State or district officials in four of the six states expressed 

some concerns about their readiness for full implementation. For 

example, officials in one Maryland district that piloted with about 4 percent 

of teachers said they will move from learning about the system to full 

implementation without sufficient time to address issues that arose during 

the pilot. Similarly, officials in another Maryland district that piloted with 

about 5 percent of teachers and 19 percent of principals said the district 

did not have sufficient time to work with teachers and principals on the 

new evaluation systems and would have benefited from another pilot 

year. The Maryland district officials said that two individuals were 

responsible for all of the evaluation systems work. These officials added 

that they anticipate budget and staff reductions as they move from their 

pilot, in which about 100 teachers and 10 principals were evaluated, to full 

implementation that will cover more than 3,000 people.

28

 27 In Maryland, RTT districts had flexibility with how to pilot their evaluation systems (e.g., 

with some teachers in all schools or with all teachers in some schools).

For example, North Carolina 

officials said districts used evaluation results to assign underperforming 

teachers to professional growth plans that are intended to help them 

improve their teaching abilities. If a teacher’s evaluation results do not 

improve, that teacher may be dismissed or face other consequences. 

Officials in Delaware and Florida said their states used evaluation results 

in their first year of full implementation to inform personnel decisions for 

28 Due in part to the difficulty of managing many changes simultaneously, including new 

curriculum and assessments in many states, in June 2013 Education offered states that 

have received ESEA waivers or RTT grants the option to request permission from 

Education to delay the use of their new evaluation systems to inform personnel 

determinations and consequences for up to 1 year. Education officials noted that many 

states are already successfully implementing these changes or have requirements in state 

law about implementation timeframes and thus may not need to request the waiver.
Page 15 GAO-13-777 Race to the Top Evaluation Systems

teachers and principals, such as retention rewards and dismissal. 

According to Hawaii officials, the state plans to fully implement its teacher 

evaluation system in SY 2013-14, but all consequences related to 

evaluations will be added the following school year. In several states, 

RTT districts decide how to use evaluation results to determine 

consequences. Ohio officials said that RTT districts were required to use 

evaluation results to inform some personnel decisions—including 

professional development, retention, and pay for performance—and the 

state surveyed RTT districts to confirm that they did so. Tennessee 

officials said that RTT districts were required to use the results of 

evaluations to inform certain personnel decisions, such as employment, 

compensation, and dismissal, but that the state did not prescribe the 

consequences attached to different ratings.
Page 16 GAO-13-777 Race to the Top Evaluation Systems

State or district officials in most RTT states (8 of the 12) said they had 

difficulty developing and using student learning objectives (SLOs) to 

assess student academic growth for teachers.29 SLOs measure student 

academic growth for teachers in nontested grades and subjects, which 

represent 65 to 75 percent of teachers nationwide, according to an RSN 

report. SLOs are learning objectives for groups of students, such as 

students in a social studies class, that use a specific measure, such as a 

course exam, to track academic progress throughout a school year.30

 29 RTT state and district officials generally discussed challenges related to student 

academic growth measures, particularly SLOs, in the context of teacher evaluation 

systems. Officials in one Maryland district said developing SLOs for principals was difficult 

because their learning goals sometimes covered few students. For example, a principal’s 

goal of improving special education outcomes might be based on only a few special 

education students within a large school.

However, some RTT state and district officials said it can be difficult to 

ensure that these learning objectives are rigorous and accurately 

measure student learning. Tennessee officials said that while SLOs are 

popular and promising in theory, they are difficult to reliably implement 

30 Reform Support Network, The View from the States: A Brief on Non-Tested Grades and

Subjects, accessed June 11, 2013, http://www2.ed.gov/about/inits/ed/implementationsupport-unit/tech-assist/resources.html. Teachers in nontested grades and subjects would 

not have student scores on state-administered standardized tests that could be 

individually attributed to them. SLOs may be developed at the state, district, or school 

level and may be used as alternative student academic growth measures for evaluating 

teachers in nontested grades and subjects, or as additional student academic growth 

measures for evaluating teachers in tested grades and subjects. In some cases, scores on 

standardized tests may be used for SLOs. Principals may also be evaluated using SLOs.

Most RTT States 

Cited Challenges 

with Developing 

and Using Certain 

Evaluation Measures, 

Addressing Teacher 

Concerns, and 

Building Capacity 

and Sustainability

RTT States Struggled 

to Develop and Use 

Student Learning 

Objectives and Assess 

Teacher Professional 

Practice Consistently
Page 17 GAO-13-777 Race to the Top Evaluation Systems

because some teachers set non-rigorous goals in order to get high 

scores. Tennessee officials further explained that some teachers selected 

a schoolwide social studies score for their SLO measure—despite having 

no connection to the subject—because students did well on that exam, 

rather than selecting learning objectives relevant to their own subject 

matter. Officials in three Maryland districts said determining how to 

measure student academic growth using learning objectives was a 

challenge because, for example, they may have difficulty assessing 

students’ abilities when they enter a class, not just when they leave. 

Officials in a New York district described the difficulty of implementing 

learning objectives in their small, rural district (see sidebar). Despite these 

challenges, RTT state and district officials said that SLOs improved their 

evaluation systems, in part by engaging teachers in the evaluation 

process and by leading to more in-depth discussions about teacher 

performance. To address some of their challenges, RTT states developed 

guidance, templates, or model learning objectives to help districts develop 

and use SLOs. In addition, states participated in an RSN-sponsored 

working group on developing SLOs. They could also access RSN 

guidance from Education’s website that outlined the benefits of learning 

objectives and provided information about the elements that comprise 

rigorous, high-quality learning objectives.31

Some RTT state and district officials said it was difficult to ensure that 

principals assess teacher professional practice consistently. For example, 

officials said it was challenging to ensure consistency in how principals 

use classroom observations and other evidence, such as lesson plans, to 

assess a teacher’s instructional methods.32 State or district officials in 6 of 

the 12 RTT states expressed concerns that, for example, some principals 

may not be appropriately identifying teachers who were ineffective and 

rating them accordingly.33

 31 Reform Support Network, Targeting Growth: Using Student Learning Objectives as a 

Measure of Educator Effectiveness, accessed June 11, 2013, 

Officials in a few of these states attributed this 

http://www2.ed.gov/about/inits/ed/implementation-support-unit/tech-assist/resources.html.

32 In some cases, other school or district staff may conduct teacher observations or help 

with evaluations.

33 RTT state and district officials generally discussed challenges related to evaluation 

consistency in the context of teacher evaluation systems. Officials in one North Carolina 

district said that using the same rubric to evaluate principals and assistant principals is 

challenging when evaluators interpret the roles of assistant principals differently in 

different schools.
Page 18 GAO-13-777 Race to the Top Evaluation Systems

to principals lacking the skill to differentiate between effective and 

ineffective teachers, or the will to rate teachers in lower categories or to 

rate them lower than under the prior evaluation system. Officials in 

Tennessee and in two North Carolina districts said evaluation data have 

shown that some teachers with low scores on their student academic 

growth component received high professional practice ratings. They said 

this may indicate that some principals are inflating scores or not 

identifying lower-performing teachers and providing critical feedback. 

Officials in another North Carolina district described a different concern 

about the mismatch in professional practice ratings and student academic 

growth. They noted that student academic growth data are not available 

until the following year and might influence how some principals assess 

teachers in the year in which the data become available. For example, 

after receiving data that shows a teacher demonstrated good student 

academic growth the prior year, a principal might overlook poor 

classroom management when observing the teacher. Organizations 

representing teachers and principals also raised concerns about 

evaluation consistency (see sidebar).

State, district, or union officials in six RTT states described efforts to 

improve consistency in principals’ evaluations of teachers, generally 

through training. In New York, officials from a state teachers’ union said 

they provided training to more than 750 principals on ensuring 

consistency when conducting teacher evaluations. Tennessee officials 

said that during the first year of implementation, principals participated in 

4 days of training and had to pass a test in order to perform classroom 

observations. During the second year, Tennessee identified principals 

who did not evaluate teachers appropriately and provided them with 

additional support and coaches. Officials also said that Tennessee plans 

to make its certification test more rigorous. Officials in one North Carolina 

district said that, in addition to providing state training and workshops on 

evaluation consistency, district administrators conduct informal classroom 

walk-throughs to observe teachers and then discuss rating consistency 

while comparing their notes with the principal’s observation ratings.

State or district officials in 11 of the 12 RTT states discussed the difficulty 

of addressing teacher concerns about the scale of evaluation reform. 

According to these officials, teachers were concerned about some of the 

significant changes in the new systems, such as the use of student 

Concerns about Magnitude 

of Change Challenged 

States’ Efforts
Page 19 GAO-13-777 Race to the Top Evaluation Systems

academic growth data in evaluations and using evaluation results to make 

personnel decisions (e.g., retention or compensation).34 For example, 

state, district, and union officials in Maryland said that teachers did not 

trust the validity of the state test scores used in some of the student 

academic growth measures. Officials in one New York district were 

concerned generally about the rise in annual testing and its use in 

evaluations to inform personnel decisions. District and union officials in 

New York said the release of teacher evaluation ratings to parents added 

to concerns about evaluation systems. Officials in one small district said 

their teachers were particularly concerned because protecting their 

anonymity might be difficult even if data are aggregated and not linked to 

individual teachers. Officials in three states and one district said they had 

difficulty convincing teachers that evaluation systems were focused on 

professional development, rather than consequences. Some RTT state 

and district officials said the simultaneous transition to new state 

assessments and the Common Core curriculum—a single set of 

educational standards in language arts and math—increased teacher 

concerns about consequences.35 For example, North Carolina officials 

said teachers were concerned about the fairness of measuring student 

academic growth while schools are implementing a new curriculum. In 

some RTT states, according to state and union officials, lengthy collective 

bargaining processes or lawsuits slowed implementation efforts.36

State and district officials said they took steps to address teacher 

concerns, in part by involving teachers in the design and implementation 

of the evaluation systems and through ongoing communication with 

teachers. State or district officials in 10 of the 12 RTT states highlighted 

efforts such as teacher participation on committees that designed the 

systems, teacher involvement in national training workshops, and regular 

communication and feedback from teachers on implementation. In 

addition, officials from all three state organizations representing teachers 

 34 According to officials, measuring student academic growth for teacher evaluations was 

new to several states.

35 The Common Core State Standards Initiative is a state-led effort, and all but five states 

have voluntarily adopted the standards.

36 Officials in two RTT states identified union lawsuits as a factor that contributed to delays 

or uncertainty during implementation. In at least one state, litigation is ongoing, in both 

state and federal court. Other states may have also faced lawsuits but did not discuss 

them in our interviews.
Page 20 GAO-13-777 Race to the Top Evaluation Systems

said they helped develop the legal framework or overarching standards 

for their states’ evaluation systems and participated on committees or 

provided training to teachers and principals to support their state’s efforts. 

To reduce teacher concerns once reform efforts were under way, officials 

in Maryland regularly distributed a document to key stakeholders that, 

among other things, provided updates related to evaluation components. 

Officials in Georgia said they made presentations in the community, held 

focus groups in districts, and provided training to help manage the culture 

shift to the new evaluation system.

State or district officials in most RTT states (9 of the 12) said they faced 

fewer concerns related to principal evaluations due to greater principal 

support, the smaller scale of implementation, or because principals were 

used to being evaluated based on student performance. According to 

North Carolina officials, superintendents used student academic growth in 

principal evaluations prior to RTT, so principals did not have the same 

level of concern as teachers. In addition, North Carolina officials noted 

that the state had 2,600 administrators compared to 95,000 teachers, 

which made principal evaluation easier to implement. Hawaii officials said 

implementing principal evaluations was a generally collaborative and 

productive process for several reasons. For instance, they said principal 

associations were relatively easy to work with, administrator assessments 

already existed, and principals understood the need for a new evaluation 

system and contributed significantly to its design. In another state, 

officials from a principals’ association echoed the view that principals 

were accustomed to being evaluated on student academic growth and 

added that principals in their state were more concerned about teacher 

evaluations than their own evaluations.

Insufficient state and district capacity challenged RTT states’ efforts to 

design and implement their evaluation systems (see fig. 3).37

 37 Capacity challenges were generally related to the design and implementation of both 

teacher and principal evaluation systems. Officials in four RTT states said that capacity 

challenges pertained to both evaluation systems, but were more pronounced with teacher 

evaluations. Officials in one state said that capacity challenges pertained only to the 

teacher evaluation system.

State or 

district officials in most of these states said they lacked either sufficient 

staff or needed expertise when they began to reform their evaluation 

systems. Some state officials also said they faced capacity challenges 

States Took Steps to 

Address Insufficient 

Capacity
Page 21 GAO-13-777 Race to the Top Evaluation Systems

related to supporting district efforts, such as reviewing and approving 

district evaluation systems and providing technical assistance. For 

example, Florida officials said that, because their RTT districts had the 

flexibility to design their own systems, it was difficult to develop solutions 

to challenges that would be applicable to all RTT districts.38 State and 

district officials said that at the local level, districts had difficulty managing 

principal workloads or prioritizing evaluation reform amid multiple 

educational initiatives. For example, officials in a New York district said 

that the time commitment required for observing and evaluating teachers 

prevented some principals from thoroughly reviewing evidence submitted 

for evaluations or providing meaningful feedback to teachers. District 

officials in New York and Maryland told us that their evaluation reform 

efforts took precedence over other initiatives, such as implementation of 

the Common Core curriculum. Building capacity to enact education 

reforms has been a recurring challenge for states and districts, as we 

have discussed in previous reports.39

Figure 3: Capacity Challenges Faced by Race to the Top States

Note: Officials in 8 of the 12 districts we spoke with discussed building staff size or expertise, 

managing principal workloads, and prioritizing evaluation reform as challenges. State officials noted 

that supporting district efforts was a challenge.

 38 As noted previously, the degree of flexibility districts had in designing their evaluation 

systems varied.

39 See GAO-11-658, GAO-12-228R, and GAO, School Improvement Grants: Education 

Should Take Additional Steps to Enhance Accountability for Schools and Contractors, 

GAO-12-373 (Washington, D.C.: April 11, 2012).
Page 22 GAO-13-777 Race to the Top Evaluation Systems

While RTT was designed to encourage education innovation and 

reform—rather than covering all costs of reform efforts—several state and 

district officials cited the high cost of designing and implementing 

evaluation systems as a challenge.40

States and districts responded to capacity challenges through different 

efforts to supplement their staff and resources (see fig. 4). Several RTT 

states also submitted amendment requests and received approval from 

Education to shift funds among RTT projects to provide additional funding 

for particular aspects of their evaluation systems. For example, 

Tennessee shifted approximately $1.1 million to support, among other 

things, additional training on evaluation systems because the state did not 

originally estimate sufficient funds for this purpose. Similarly, New York 

increased its budget for its evaluation systems by $11.9 million by shifting 

funds to develop its student academic growth model, pilot evaluation 

system software, and provide additional resources to districts.

For example, officials in Hawaii and 

Delaware (see sidebar) noted that they underestimated how much it 

would cost to develop these systems. Similarly, officials in 7 of the 12 

districts we spoke with said their RTT funds did not cover the costs of 

reforming their evaluation systems. For example, one small, rural New 

York district spent about $62,400 on its teacher and principal evaluation 

systems in addition to the $22,856 it received in RTT funds. Other New 

York districts faced similar challenges. A 2011 survey conducted by the 

New York State Council of School Superintendents shows that 81 percent 

of responding superintendents were concerned that cost considerations 

might prevent their districts from soundly implementing new evaluation 

requirements. Cost may have been more of a challenge for some districts 

because they were responsible for a significant part of the design and 

implementation work. Six of the 7 districts in which officials raised cost as 

a capacity challenge were in Maryland and New York, both of which 

provide RTT districts with significant flexibility to design their own 

systems. Officials in Tennessee explained that some RTT districts in their 

state did not have funding concerns because they used the evaluation 

system and data system provided by the state.

 40 As previously noted, capacity challenges were generally related to the design and 

implementation of both teacher and principal evaluation systems.
Page 23 GAO-13-777 Race to the Top Evaluation Systems

Figure 4: Examples of Race to the Top State and Selected District Efforts to 

Address Capacity Challenges

State or district officials in most RTT states (10 of the 12) said that fewer 

staff or other resources after RTT grant funds are no longer available 

could affect their ability to sustain their evaluation systems. For example, 

Rhode Island officials said they will likely lose staff that they hired using 

RTT funds because the state may not be able to use other education 

funds to make these positions permanent. Officials in New York said that 

with the loss of RTT funding, the state will have fewer staff to review 

district evaluation plans every year and to provide technical assistance to 

districts, as well as to manage the analysis of statewide evaluation data. 

District of Columbia officials were concerned that without RTT funds, they 

would be unable to pay the contractor that operates the student academic 

growth model used by its charter school districts.

Officials from all 12 RTT states said they are considering how to sustain 

their evaluation systems after RTT grant funds are no longer available. 

Officials in a few of these states discussed some of the difficulties they 

have faced in preparing for sustainability, such as turnover in state 

leadership and uncertainty over future funding levels, and a few officials 

provided examples of how they might address sustainability. For 

Finding Resources to 

Replace RTT Funds 

Challenges States’

Sustainability Efforts
Page 24 GAO-13-777 Race to the Top Evaluation Systems

example, Hawaii officials said they are considering how to reallocate 

funds to sustain the systems but are concerned about the availability of 

other federal and state funds to do so. Georgia officials said they are 

collaborating with stakeholders to develop a sustainability plan—to be 

completed in summer 2013. In addition, Florida officials said they were 

working to ensure that they have in-house expertise on all aspects of the 

evaluation systems. For example, contractors who assisted with the 

state’s student academic growth component will train state staff on how to 

run the models. 

Officials in 5 of the 12 RTT states told us more information from 

Education could help address their concerns about sustaining their 

evaluation systems and other reforms after RTT grant funds are no longer 

available. Specifically, state and district officials from some of these 

states told us they were concerned about or would like guidance on how 

to use other federal funds to support their evaluation systems. For 

example, officials in one state said Education issued some guidance on 

acceptable uses of ESEA funding, but could provide more concrete 

information on how best to leverage those funds for RTT initiatives. In 

addition, Education officials told us a few states have requested technical 

assistance to support their sustainability planning. Officials from four 

states told us it was too soon for them to know whether they would need 

Education’s assistance with sustainability.
Page 25 GAO-13-777 Race to the Top Evaluation Systems

Education developed a new process to monitor RTT states’ progress 

toward meeting their RTT goals, including those related to teacher and 

principal evaluation systems.41 Education officials said that the RTT 

monitoring process differs from the department’s other monitoring efforts 

in that Education has more frequent contact with the states in order to 

identify and address implementation challenges. In addition, the new 

process emphasizes states’ continuous improvement and quality of RTT 

reforms, rather than focusing solely on compliance with laws and 

regulations and the ability of states to meet their time frames.42

Education officials said they work to identify and address obstacles to the 

goals states established in their RTT plans through ongoing 

communication, including monthly monitoring calls, the amendment 

consideration process, and other contacts with RTT state officials. To 

assess the quality of implementation efforts, officials said they consider 

each state’s progress toward its goals and timelines, risk factors and 

Officials 

said the intensity of communication with RTT states and the quality 

standards are greater for RTT than for Education’s previous monitoring 

efforts. Education developed the new process to provide assistance to 

RTT states as they implement comprehensive reforms and to differentiate 

support based on individual state needs.

 41 See Race to the Top Program Review Guide. The same monitoring process is used for 

teacher and principal evaluation systems and other reforms funded through RTT grants. 

42 We found that the RTT monitoring process exceeds the minimum requirements 

established in Education’s 2009 Handbook for the Discretionary Grant Process. While 

Education requires its offices to prepare annual monitoring reports and conduct quarterly 

fiscal reviews of all of its discretionary grant programs, the RTT process also requires 

monthly progress updates, annual on-site program reviews, and progress reports updated 

on an ongoing basis, among other components.

Education Supports 

RTT State 

Implementation 

Efforts through 

Monitoring and 

Technical Assistance

Education Monitors States 

Using a New Process to 

Hold Them Accountable 

for Quality of 

Implementation
Page 26 GAO-13-777 Race to the Top Evaluation Systems

strategies for addressing them, and the state’s own assessment of its 

quality of implementation, among other factors. For example, in addition 

to verifying that a state implemented an evaluation tool, such as a test or 

performance measure, Education officials work with the state to ensure 

that the tool is meeting the state’s needs. Instead of focusing solely on 

RTT compliance, program officers also help identify areas in which 

Education can assist states in meeting their goals, according to Education 

officials.

Officials from 8 of the 12 RTT states expressed generally positive views 

about Education’s RTT monitoring activities. Some said, for example, that 

Education officials were collaborative, well-informed, and that they 

generally provided useful feedback. For example, officials from one state 

said that Education staff were very detailed and thorough in monthly 

monitoring calls and that they usually provided actionable feedback. 

Officials from another state said they spoke almost daily with Education 

officials and received strong support. They noted that, as a result, 

monitoring reviews were not stressful, and they were not surprised by the 

results. Officials from another state said they appreciated the discussion 

with Education officials about the state’s amendment requests and how 

Education worked with them to ensure that the state maintained its 

original RTT goals.

While RTT state officials expressed generally positive views about the 

monitoring process overall, officials in nine states expressed concerns 

about specific aspects of the process, including delays in the amendment 

process, time-consuming monthly calls and related requirements, and 

slow feedback from Education after site visits. Officials from one state 

said monitoring requirements seemed more burdensome than those for 

other federal education programs. Education officials stated that they 

have revised some aspects of their monitoring process in response to 

state feedback. For example, they modified the monthly monitoring call 

and onsite review protocols, revised the amendment process and dollar 

threshold amounts that require approval, and worked to explain the 

rationale and use of the information Education requests.

To ensure that states are held accountable for meeting their RTT goals 

for teacher and principal evaluation systems, Education may take the 

following corrective actions for states that have not demonstrated 

adequate progress in implementing their systems:
Page 27 GAO-13-777 Race to the Top Evaluation Systems

• Conditional amendment approval. If Education has concerns about 

a state’s requested amendments to its RTT plans, it may grant 

conditional approval, requiring the state to provide additional 

information over a period of time. For example, Rhode Island 

submitted a proposed amendment requesting a change related to its 

use of SLOs. Education approved the request on the condition that 

the state provide additional information, such as quarterly progress 

updates during SY 2012-13 and additional reports.43

• High-risk status. Education placed 2 of the 12 RTT states—Georgia 

and Hawaii—on high-risk status because officials determined that the 

states required intensive attention and support in order to meet their 

RTT goals.

In addition, 

Maryland received approval to decrease the percentage of the 

evaluation component that is based on student academic growth 

models on the condition that the state provide Education a plan for a 

statewide field test of its evaluation systems. Maryland was also 

required to commit to measuring student academic growth using 

common assessments of high school teachers and principals when 

those assessments are available, among other requirements. 

Education may also elect not to approve an amendment request.

44

 43 We previously found that Education applied greater scrutiny to requests that involved 

significant changes to RTT grantees’ planned activities, often by requiring that grantees 

provide additional information or seek consultation from issue-area experts within the 

department. See 

In July 2012, Education placed the teacher and principal 

evaluation portion of Georgia’s RTT grant on high-risk status because 

officials were concerned about the overall strategic planning, 

evaluation, and project management of the evaluation system. 

Education officials also expressed concern that Georgia had 

requested two major amendments that seemed to constitute 

significant changes to the evaluation system in the state’s approved 

plan. As a result of the high-risk designation, Georgia was required to 

provide Education a revised work plan for its system, monthly updates 

in accordance with the work plan, and related information. As of July 

2013, Education officials said the evaluation system portion of 

Georgia’s RTT grant remains on high-risk status because of 

Education’s continued concerns about the quality of implementation. 

In December 2011, Education designated Hawaii’s entire RTT grant

GAO-12-228R.

44 Under Education’s regulations, if Education determines that a grantee is “high-risk,” it 

may impose special conditions or restrictions on the grantee. Among other reasons, a 

grantee may be considered high-risk if the grantee has a history of unsatisfactory 

performance, is not financially stable, or is otherwise not responsible. 34 C.F.R. § 80.12. 
Page 28 GAO-13-777 Race to the Top Evaluation Systems

as high-risk because the state experienced major delays and made 

inadequate progress on implementing its systems and because the 

scope and breadth of amendment requests indicated a potentially 

significant shift in the state’s approved plans. Education temporarily 

placed Hawaii on a cost-reimbursement basis, which required the 

state to submit receipts for expenditures to the department prior to 

drawing down grant funds. The state was also required to submit 

documentation prior to obligating funds and to submit a revised scope 

of work and budget. As of July 2013, Education had removed Hawaii’s 

high-risk designation based on the state’s demonstrated progress in 

implementing its RTT reforms, including its evaluation systems.

• Additional information. Education has required certain reporting or 

follow-up information, other than that included in conditional approval 

of amendments or high-risk status, and has used other measures 

deemed appropriate. For example, according to Education officials, 

one state that experienced procurement problems is required to 

provide monthly procurement information to Education.

• Withholding of funds. Although Education may withhold grant funds 

from states if they do not comply with the terms of the award,45

Education officials said they have not withheld funds from any RTT 

state. Officials added that states have always demonstrated progress 

toward addressing Education’s concerns.

Education helps states meet their RTT goals and implement high-quality 

reforms by providing technical assistance, including access to experts 

and information on options for evaluation systems. Education officials 

said technical assistance helps states resolve implementation issues, 

including those identified through the monitoring process. Most RTT 

federal assistance is provided by the contractor-supported RSN, and 

Education also provides some technical assistance to RTT states.46

 45 If a grantee materially fails to comply with any term of an award, Education may take 

one or more of the following actions, as appropriate in the circumstances: (1) temporarily 

withhold cash payments pending correction of the deficiency or more severe enforcement 

action; (2) disallow (i.e., deny both use of funds and matching credit for) all or part of the 

cost of the activity or action not in compliance; (3) wholly or partly suspend or terminate 

the current award for the grantee’s program; (4) withhold further awards for the program; 

or (5) take other remedies that may be legally available. 34 C.F.R. § 80.43.

RSN 

officials said they work closely with Education staff to learn about the 

46 Some states said they also obtained technical assistance from entities outside the 

federal government, such as other states and nonprofit organizations.

Education Provides 

Technical Assistance to 

Help States Resolve 

Implementation Issues
Page 29 GAO-13-777 Race to the Top Evaluation Systems

types of technical assistance that might be useful to states on teacher 

and leader effectiveness, including teacher and principal evaluations, as 

well as other RTT topics.

From 2010 through March 2013, RSN provided technical assistance on 

teacher and leader effectiveness in group settings—such as webinars 

and in-person meetings—to RTT states, as well as individualized 

technical assistance (see fig. 5). RSN officials said they provide 

individualized assistance to states when requested, particularly for states 

in more advanced stages of implementation with needs that could not be 

met through larger group technical assistance activities. RSN also 

developed publications related to teacher and leader effectiveness, 

including case studies, tool kits, and lessons learned, and has provided 

them through the RTT grantee web portal. These publications included 

longer reports on school reform and shorter briefs, such as a paper that 

described rules governing classroom observations used in teacher 

evaluations in selected RTT states.

Figure 5: Cases of Technical Assistance Provided by the Reform Support Network 

to Race to the Top States on Teacher and Leader Effectiveness, Calendar Years 

2010-2013

Note: Figure reflects assistance provided through March 2013. RSN provided the 15 cases of 

individualized technical assistance to 6 of 12 RTT states upon request.

RSN has worked to strengthen the quality of its technical assistance and 

adapt to states’ changing needs, according to Education and RSN 

officials. They said that early in the contract, RSN revised its approach to 
Page 30 GAO-13-777 Race to the Top Evaluation Systems

better meet the needs of states. For example, in response to state 

feedback, RSN provided states with access to education practitioners 

who had worked in schools rather than experts without hands-on 

experience, as they had done in the initial stages of the contract. RSN 

officials also said issues for which states requested technical assistance 

changed as implementation progressed, and RSN adapted its technical 

assistance accordingly. For example, early in implementation, states 

often requested assistance with designing evaluation systems, 

communicating with stakeholders, working with unions, and measuring 

growth in nontested grades and subjects, according to RSN officials. As 

implementation progressed, states requested assistance with issues such 

as the consistency of observations and the sustainability of evaluation 

systems.

Officials from 10 of the 12 RTT states told us that Education’s technical 

assistance related to teacher and principal evaluation systems was 

generally helpful, and officials in several states said assistance had 

improved since the start of the contract. Officials from Hawaii said RSN 

had helped states by sharing existing knowledge and developing new 

information. Officials in Massachusetts told us that RSN’s in-person 

meetings had been especially helpful because they provided a platform 

for states to share best practices. Although most states were 

complimentary of RSN assistance, officials in some states said RSN and 

Education could improve technical assistance by providing additional 

information on specific topics, such as information about states that have 

successfully implemented evaluation systems and more opportunities to 

share lessons learned.

A recent survey by RSN also indicates that states are generally satisfied 

with the contractor’s technical assistance on teacher and principal 

evaluation systems. In March 2013, RSN surveyed and obtained 

responses from officials in all RTT states regarding their perception of 

technical assistance, including assistance provided through the teacher 

and leader effectiveness community of practice.47

 47 RSN surveyed all 19 RTT states, including the 12 Phase 1 and Phase 2 RTT states and 

the 7 Phase 3 states. RSN surveyed RTT state leads—officials with primary responsibility 

for administering RTT. 

Sixteen of the 18 states 

that participated in teacher and leader effectiveness assistance reported 

that they were satisfied or very satisfied with the assistance, and the 

remaining states were neutral. On multiple dimensions, the state officials 
Page 31 GAO-13-777 Race to the Top Evaluation Systems

rated assistance with teacher and leader effectiveness higher than other 

areas and higher than RSN activities overall.48 States also identified 

opportunities for strengthening technical assistance by ranking potential 

topics on the basis of impact and urgency. For teacher and leader 

effectiveness, states ranked continuous improvement of teacher 

evaluation as one of the top areas of interest, according to RSN. Officials 

in a few states mentioned that they would like more opportunities to 

collaborate and learn from one another.

Education plans to provide information to RTT states on sustaining 

teacher and principal evaluation systems and other reforms, but 

Education officials said they have not yet done so. Education planned to 

launch a new workgroup in the summer of 2013 to help states consider 

how to sustain their evaluation systems after the RTT grant ends. Draft 

plans for the work group included providing expert and peer-to-peer 

support and developing a sustainability rubric. The plans also included 

providing workshops on sustainability efforts, including ones on state 

capacity, performance management, and communication, and eventually 

developing and sharing case studies. In July 2013, Education officials 

said they had postponed work in this area until fall 2013. Although 

Education has not asked states to provide specific plans for addressing 

sustainability, department officials said they have learned about state 

plans through ongoing communication with states. For example, a few 

states discussed their sustainability planning during monthly monitoring 

calls. In addition, Education obtained information on state sustainability 

strategies through RTT applications. In general, states provided this 

information on RTT reforms as a whole. We did not identify any states as 

having provided a sustainability strategy specific to teacher and principal 

evaluation systems.

 48 Other areas of assistance provided through RSN communities of practice include 

instructional improvement/ data systems, school turnaround, state educational agency 

capacity building, and stakeholder communications and engagement. States were asked 

to rate the impact of RSN technical assistance on RTT implementation on a scale of 1 to 

5, with 1 representing low impact and 5 representing high impact. States rated the impact 

of teacher and leader effectiveness assistance on RTT implementation an average of 3.4 

out of 5, compared to 2.4 for all RSN activities and 2.1 for state education agency capacity 

building. When asked about the extent to which RSN support has helped build state 

capacity, states rated the impact of teacher and leader effectiveness assistance higher 

than they did other RSN efforts.

Education Plans to 

Provide RTT States and 

Nongrantees Additional 

Information to Support 

State Efforts
Page 32 GAO-13-777 Race to the Top Evaluation Systems

To allow states more time to accomplish the goals and deliverables they 

committed to in their RTT plans, Education officials will consider requests 

for no-cost extensions, but they have not determined how to provide 

technical assistance during the extension period. States may request 

extensions on a case-by-case basis for more time to spend awarded 

funds for those aspects of their RTT reforms that require additional work. 

If approved, a state could have until September 30, 2015 to obligate and 

liquidate its remaining RTT grant funds.49

Education has provided some information on RTT lessons learned to RTT 

and nongrantee states, including information on certain aspects of 

evaluation systems. Education has taken steps to provide nongrantee 

states with access to promising practices through the department’s 

existing mechanisms, including the secure RTT grantee website and 

communities of practice, as we recommended in our 2011 report.

According to Education officials, 

states that request no-cost extensions will be required to provide to 

Education their plans to address sustainability, among other information. 

As of July 2013, Education officials had approved two no-cost extensions 

related to teacher and principal evaluation systems, and officials in an 

additional state told us they had submitted an extension request related to 

their evaluation systems. Officials in 6 more of the 12 RTT states told us 

they are considering requesting extensions related to their evaluation 

systems. However, it is not clear what technical assistance would be 

available to states approved for no-cost extensions. The current contract 

for technical assistance ends in September 2014, and RSN officials said 

they do not have plans to sustain technical assistance beyond the 

duration of the current contract. Education officials said they were working 

to identify options for providing continued technical assistance.

50

 49 The actual extension date for each state, if requested and approved, will vary. 

RSN 

officials said they were in the process of developing public access to the 

RSN web portal to allow nongrantee states to access some, but not all, 

materials. In the meantime, nongrantees can access some information 

through Education’s website, including materials generated through 

communities of practice and individualized technical assistance. 

Education posts to its website annual reports for each RTT state that 

include information on lessons learned. Education’s RTT staff also said 

they collaborated with other Education program officials on a series of 

webinars for all states, including one on SLOs and another on schoolwide 

50 GAO-11-658.
Page 33 GAO-13-777 Race to the Top Evaluation Systems

student academic growth data. In addition to the materials currently 

available, Education officials told us that they were developing additional 

resources and materials on topics such as SLOs, observation rubrics, 

rating inflation, teacher engagement, data analytics, and leadership 

development. Education identified some products for targeted 

dissemination and presented them in conferences, cross-program 

meetings, and to organizations such as the National Governors 

Association, in order to promote awareness of the resources available. 

Education is also working to develop a more robust dissemination plan 

that includes ways to reach people other than state-level leaders, 

according to officials.

Education created the RTT grant program to encourage sweeping 

changes in K-12 education. RTT spurred changes to the way states and 

districts evaluate their teachers and principals, particularly with the 

addition of student academic growth data as a factor in assessing 

effectiveness. Education has been proactive in monitoring states’

progress in implementing their evaluation systems, and the department’s 

continued monitoring and assistance will be important to help RTT states 

overcome challenges and implement the reforms to which they 

committed. In addition, Education’s new monitoring process has resulted 

in a wealth of information on states’ efforts. As a result, Education is 

uniquely positioned to use the lessons learned from RTT states to inform 

other states’ efforts to improve teacher effectiveness and ultimately raise 

student academic achievement.

We provided a draft of this report to the Department of Education for 

review and comment. Their comments are reproduced in appendix I.

Education also provided technical comments, which we incorporated into 

the report.

Concluding 

Observations

Agency Comments 

and Our Evaluation
Page 34 GAO-13-777 Race to the Top Evaluation Systems

We are sending copies of this report to the appropriate congressional 

committees and the Secretary of Education. In addition, the report is 

available at no charge on GAO’s website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-7215 or scottg@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made major contributions to this report 

are listed in appendix II.

Sincerely Yours,

George A. Scott

Director, Education, Workforce,

and Income Security Issues
Appendix I: Comments from the 

U.S. Department of Education

Page 35 GAO-13-777 Race to the Top Evaluation Systems

Appendix I: Comments from the 

U.S. Department of Education
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 36 GAO-13-777 Race to the Top Evaluation Systems

George A. Scott, Director (202) 512-7215 or scottg@gao.gov

In addition to the contact named above, Elizabeth Morrison, Assistant 

Director, Nisha R. Hazra, Marissa Jones, and Michael Kniss made 

significant contributions to this report. Also contributing to this report were 

Deborah Bland, Sarah Cornetto, Jamila Jones Kennedy, Amy MoranLowe, Jean McSween, Mimi Nguyen, Jason Palmer, Kathleen van 

Gelder, and Rebecca Woiwode.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 37 GAO-13-777 Race to the Top Evaluation Systems

School Improvement Grants: Education Should Take Additional Steps to 

Enhance Accountability for Schools and Contractors. GAO-12-373. 

Washington, D.C.: April 11, 2012.

Race to the Top: Characteristics of Grantees’ Amended Programs and 

Education’s Review Process. GAO-12-228R. Washington, D.C.: 

December 8, 2011.

Race to the Top: Reform Efforts are Under Way and Information Sharing 

Could Be Improved. GAO-11-658. Washington, D.C.: June 30, 2011.

Department of Education: Improved Oversight and Controls Could Help 

Education Better Respond to Evolving Priorities. GAO-11-194. 

Washington, D.C.: February 10, 2011.

Grant Monitoring: Department of Education Could Improve Its Processes 

with Greater Focus on Assessing Risks, Acquiring Financial Skills, and 

Sharing Information. GAO-10-57. Washington, D.C.: November 19, 2009.

Student Achievement: Schools Use Multiple Strategies to Help Students 

Meet Academic Standards, Especially Schools with Higher Proportions of 

Low-Income and Minority Students. GAO-10-18. Washington, D.C.: 

November 16, 2009.

No Child Left Behind Act: Enhancements in the Department of 

Education’s Review Process Could Improve State Academic 

Assessments. GAO-09-911. Washington, D.C.: September 24, 2009.

Teacher Quality: Sustained Coordination among Key Federal Education 

Programs Could Enhance State Efforts to Improve Teacher Quality. 

GAO-09-593. Washington, D.C.: July 6, 2009.

No Child Left Behind Act: Improvements Needed in Education’s Process 

for Tracking States’ Implementation of Key Provisions. GAO-04-734. 

Washington D.C.: September 30, 2004.

Related GAO Products

Department of 

Education
Related GAO Products

Page 38 GAO-13-777 Race to the Top Evaluation Systems

Recovery Act: Opportunities to Improve Management and Strengthen 

Accountability over States’ and Localities’ Uses of Funds. GAO-10-999. 

Washington, D.C.: September 20, 2010.

Recovery Act: One Year Later, States’ and Localities’ Uses of Funds and 

Opportunities to Strengthen Accountability. GAO-10-437. Washington, 

D.C.: March 3, 2010.

Recovery Act: Status of States’ and Localities’ Use of Funds and Efforts 

to Ensure Accountability. GAO-10-231. Washington, D.C.: December 10, 

2009.

Recovery Act

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